exhibitaimpactofpastduep

To: Files From: Santander Consumer USA Holdings Inc. Date: June 30, 2018 Subject: Past due status - servicing practices change effective 1/1/17: Materiality Analysis A. Background The Company considers an account delinquent when an obligor fails to pay the required minimum portion of the scheduled payment by the due date. This materiality analysis only considers the measurement of the impact of a change in past due status of a customer, as discussed below. Servicing Practice at SC: Pre 1/1/17: A Chrysler Capital retail installment contract was considered current if the borrower has made all prior payments in full and at least 90% of the payment currently due, and a non-Chrysler Capital retail installment contract was considered current if the borrower has made all prior payments in full and at least 50% of the payment currently due. Post 1/1/17: For Core loans originated after 1/1/2017, SC determines past due status using a 90% required minimum payment threshold, while continuing to use a 50% minimum payment threshold to report past due status on Core loans originated prior to 1/1/2017. The application of SC’s servicing practices, and related past due disclosure, has been to report the customer past due status consistent with the Company’s dealings with the customer established based on our servicing practices. Transparent disclosure of this past due measurement practice is provided to investors via our SEC filings and/or securitization documents. SEC comments: We understand the Staff believes that the Company’s change in reporting the past due status of loans based on a 90% versus a 50% payment threshold is a change in accounting principle, and the 90% minimum payment practice should be applied consistently to all loans for all periods presented. We further understand the Staff believes that the terms of the written loan contract should determine the past due status of a loan notwithstanding alternative terms agreed with a borrower during the loan servicing. Company’s Analysis: In consideration of the SEC’s position and comments prior to the filing of the SC Q2 2018 10-Q, we have performed a materiality analysis fully illustrating the impacts of the change to the financial statements and footnote disclosures to reflect the past due status of a customer based on receipt of substantially all (more than 90%) of the contractually required payment. B. Materiality Analysis (SAB 99) We performed an analysis of the presumed effect to prior periods, had the past due status of a loan been consistently measured by the company receiving a 90% or higher minimum payment (i.e., substantially all of the contractual payment due), as compared to a 50% or higher minimum payment threshold. The materiality analysis measures the impact to the historical disclosure of the past due status of all loans, and further assumes that certain loans could have entered nonaccrual or charge off status more quickly had the 90% threshold been applied consistently for all loans. Discussion Management has determined, when considering all quantitative and qualitative factors, consistent with the SEC Staff Accounting Bulletin (“SAB”) Topic 1M, that the adjustments resulting from the application of minimum payment requirement, individually or in the aggregate are not material and do not warrant a restatement/ revision of the consolidated financial statements already filed with the SEC, and do not require adjustment to the June 30, 2018 financial statements prior to filing. Page 1 of 9 Privileged and Confidential

Quantitative Analysis • Past Due Status (footnote disclosure): Management assessed the change to each reported category of past due status and the trends of the changes over the reporting periods. While there is no specific guiding principle, as an initial starting point management applied a threshold of 10% impact (individual and aggregate basis) with respect to specific past due categories in the updated disclosures as compared to that previously disclosed, and in no instances were the differences greater than this threshold. Our Assessment: None of the absolute differences were greater than 10% of the previously reported amounts. The highest potential impact was 6.6% for a category of past due status at a quarter end, and the trends evident across the reporting periods were not otherwise skewed. The updated amounts did not indicate a situation whereby a user of the financial statements could be materiality misled about the past due status of borrowers just based on the quantitative impacts. • Financial Statement (Balance Sheet, Income Statement and Statement of Cash flows): While recognizing that no single threshold is a determinant of materiality, management has used the following thresholds as an initial starting point for the quantitative assessment of materiality: • Quarterly income statement: 10% impact (individual and aggregate basis) with respect to a particular item • Annual income statement: 5% impact (individual and aggregate basis) with respect to a particular item • Balance Sheet: 5% impact (individual and aggregate basis) with respect to a particular item • Other disclosures: 10% impact (individual and aggregate basis) with respect to a particular item Our Assessment: • Income Statement and Balance Sheet: Management concluded that in “no” instance was the above threshold breached and therefore this change did not have any quantitatively material impact on the income statement and the balance sheet. There were no quantitative outliers which could materially impact a user of the financial statements. • Other Impacts, including statement of cash flows and related footnotes: Management notes that these potential errors have no impact to the net cash provided by operating activities, investing activities or financing activities as it relates to the Statement of Cash Flows, only impacting certain line items within the operating activities section of the statement and in all instances the effect being less than 0.2%. There were no quantitatively material impacts to any of the other assessed footnotes. • In addition, when considering the guidance in SAB 108, Considering the Effects of Prior Year Misstatements when Quantifying Misstatements in Current Year Financial Statements (now codified in ASC 250), the standard first requires one to evaluate previously issued financial statements under the rollover method, and none of the impacts were above the established thresholds. Furthermore, correcting the cumulative balance sheet potential error in the current period (Q2’18) potentially would impact reported three and six months ended June 30, 2018 pre-tax income by less than 5% (by ~ 4% and 2%, respectively). Page 2 of 9 Privileged and Confidential

ANALYSIS Past due status disclosure: A summary of the quantitative impact of the potential errors1 to past due status disclosures is as follows (dollars in thousands): As of % of % of As of % of % of As of % of % of 06/30/2018 reported corrected 03/31/2018 reported corrected 12/31/2017 reported corrected A. Delinquencies for our retail installment contracts held for investment: Principal, 30-59 days past due, as reported 2,535,166 2,238,425 2,827,678 Corrections 80,672 3.2% 3.1% 71,921 3.2% 3.1% 115,058 4.1% 3.9% Principal, 30-59 days past due, corrected 2,615,838 2,310,346 2,942,736 Delinquent principal over 59 days, as reported 1,151,410 1,089,648 1,544,583 Corrections 63,762 5.5% 5.2% 59,533 5.5% 5.2% 90,388 5.9% 5.5% Delinquent principal over 59 days, corrected 1,215,172 1,149,181 1,634,971 Total delinquent principal, as reported 3,686,576 3,328,073 4,372,261 Corrections 144,434 3.9% 3.8% 131,454 3.9% 3.8% 205,445 4.7% 4.5% Total delinquent principal, as corrected $ 3,831,010 $ 3,459,527 $ 4,577,706 A1. Delinquencies as a % of for our retail installment contracts held for investment: Principal, 30-59 days past due, as reported 9.2% 8.6% 10.9% Corrections 0.3% 3.2% 3.1% 0.3% 3.2% 3.1% 0.4% 4.1% 3.9% Principal, 30-59 days past due, corrected 9.5% 8.9% 11.3% Delinquent principal over 59 days, as reported 4.2% 4.2% 5.9% Corrections 0.2% 5.6% 5.3% 0.2% 5.5% 5.2% 0.3% 5.9% 5.6% Delinquent principal over 59 days, corrected 4.4% 4.4% 6.3% Total delinquent principal, as reported 13.5% 12.8% 16.8% Corrections 0.5% 3.9% 3.8% 0.5% 4.0% 3.8% 0.8% 4.7% 4.5% Total delinquent principal, as corrected 14.0% 13.3% 17.6% As of % of % of As of % of % of As of % of % of As of % of % of 09/30/2017 reported corrected 06/30/2017 reported corrected 03/31/2017 reported corrected 12/31/2016 reported corrected A. Delinquencies for our retail installment contracts held for investment: Principal, 30-59 days past due, as reported 2,580,226 2,709,606 2,345,995 2,925,503 Corrections 110,947 4.3% 4.1% 130,128 4.8% 4.6% 98,728 4.2% 4.0% 152,161 5.2% 4.9% Principal, 30-59 days past due, corrected 2,691,173 2,839,734 2,444,723 3,077,664 Delinquent principal over 59 days, as reported 1,464,543 1,417,461 1,153,369 1,526,743 Corrections 80,323 5.5% 5.2% 90,372 6.4% 6.0% 72,318 6.3% 5.9% 100,012 6.6% 6.1% Delinquent principal over 59 days, corrected 1,544,866 1,507,833 1,225,687 1,626,755 Total delinquent principal, as reported 4,044,769 4,127,067 3,499,364 4,452,246 Corrections 191,270 4.7% 4.5% 220,500 5.3% 5.1% 171,046 4.9% 4.7% 252,173 5.7% 5.4% Total delinquent principal, as corrected $ 4,236,039 $ 4,347,567 $ 3,670,410 $ 4,704,419 A1. Delinquencies as a % of for our retail installment contracts held for investment: Principal, 30-59 days past due, as reported 9.8% 9.9% 8.6% 10.7% Corrections 0.4% 4.3% 4.1% 0.5% 4.8% 4.6% 0.4% 4.2% 4.1% 0.6% 5.2% 5.0% Principal, 30-59 days past due, corrected 10.2% 10.4% 9.0% 11.3% Delinquent principal over 59 days, as reported 5.6% 5.2% 4.2% 5.6% Corrections 0.3% 5.5% 5.2% 0.3% 6.4% 6.0% 0.3% 6.3% 5.9% 0.4% 6.6% 6.2% Delinquent principal over 59 days, corrected 5.9% 5.5% 4.5% 5.9% Total delinquent principal, as reported 15.3% 15.0% 12.8% 16.3% Corrections 0.7% 4.8% 4.5% 0.8% 5.4% 5.1% 0.6% 4.9% 4.7% 0.9% 5.7% 5.4% Total delinquent principal, as corrected 16.1% 15.9% 13.5% 17.2% 1 The variance is presented as both a percentage of the originally reported figure (left percentage column) and of the corrected figure (right percentage column). Page 3 of 9 Privileged and Confidential

Financial Statements: The impact of this potential error, both individually and in aggregate, on financial statement line items in presented periods (consistent with periods2 that will be presented in the SC Q2 2018 10-Q3), is as follows (dollars in thousands, except per share): Income Statement (Rollover Method)4 For the six For the six For the three For the three months ended % of % of months ended % of % of months ended % of % of months ended % of % of 06/30/2018 reported corrected 06/30/2017 reported corrected 06/30/2018 reported corrected 06/30/2017 reported corrected Interest on finance receivables and loans, as reported $ 2,270,673 $ 2,441,438 $ 1,156,536 $ 1,232,252 Corrections $ (1,461) (0.1%) (0.1%) $ (2,068) (0.1%) (0.1%) $ (1,461) (0.1%) (0.1%) $ (2,068) (0.2%) (0.2%) Interest on finance receivables and loans, as corrected $ 2,269,212 $ 2,439,370 $ 1,155,075 $ 1,230,184 Net finance and other interest income, as reported $ 2,094,480 $ 2,249,110 $ 1,068,639 $ 1,135,126 Corrections $ (1,461) (0.1%) (0.1%) $ (2,068) (0.1%) (0.1%) $ (1,461) (0.1%) (0.1%) $ (2,068) (0.2%) (0.2%) Net finance and other interest income, as corrected $ 2,093,019 $ 2,247,042 $ 1,067,178 $ 1,133,058 Provision for credit losses, as reported $ 811,570 $ 1,155,568 $ 352,575 $ 520,555 Corrections $ 3,987 0.5% 0.5% $ 16,074 1.4% 1.4% $ 3,987 1.1% 1.1% $ 16,074 3.1% 3.0% Provision for credit losses, as corrected $ 815,557 $ 1,171,642 $ 356,562 $ 536,629 Pre-tax income, as reported $ 748,255 $ 569,536 $ 448,645 $ 348,108 Corrections $ (5,447) (0.7%) (0.7%) $ (18,142) (3.2%) (3.3%) $ (5,447) (1.2%) (1.2%) $ (18,142) (5.2%) (5.5%) Pre-tax income, as corrected $ 742,808 $ 551,394 $ 443,198 $ 329,966 Net income, as reported $ 576,940 $ 408,102 $ 334,641 $ 264,675 Corrections (4,200) (0.7%) (0.7%) (11,793) (2.9%) (3.0%) (4,063) (1.2%) (1.2%) (11,793) (4.5%) (4.7%) Net income, as corrected $ 572,740 $ 396,309 $ 330,578 $ 252,882 Comprehensive income, as reported $ 588,979 $ 407,703 $ 333,880 $ 257,031 Corrections $ (4,200) (0.7%) (0.7%) $ (11,793) (2.9%) (3.0%) $ (4,063) (1.2%) (1.2%) $ (11,793) (4.6%) (4.8%) Comprehensive income, as corrected $ 584,779 $ 395,910 $ 329,817 $ 245,238 EPS (diluted), as reported $ 1.59 $ 1.13 $ 0.92 $ 0.74 Corrections $ (0.01) (0.6%) (0.6%) $ (0.03) (2.7%) (2.7%) $ (0.01) (1.1%) (1.1%) $ (0.03) (4.1%) (4.2%) EPS (diluted), as corrected $ 1.58 $ 1.10 $ 0.91 $ 0.71 For the three For the three For the nine For the three months ended % of % of months ended % of % of months ended % of % of months ended % of % of 03/31/2018 reported corrected 03/31/2017 reported corrected 09/30/2017 reported corrected 09/30/2017 reported corrected Interest on finance receivables and loans, as reported $ 1,114,137 $ 1,209,186 $ 3,626,497 $ 1,185,059 Corrections $ (1,247) (0.1%) (0.1%) $ (1,473) (0.1%) (0.1%) $ (1,824) (0.1%) (0.1%) $ (1,824) (0.2%) (0.2%) Interest on finance receivables and loans, as corrected $ 1,112,890 $ 1,207,713 $ 3,624,673 $ 1,183,235 Net finance and other interest income, as reported $ 1,025,841 $ 1,113,984 $ 3,308,231 $ 1,059,121 Corrections $ (1,247) (0.1%) (0.1%) $ (1,473) (0.1%) (0.1%) $ (1,824) (0.1%) (0.1%) $ (1,824) (0.2%) (0.2%) Net finance and other interest income, as corrected $ 1,024,594 $ 1,112,511 $ 3,306,407 $ 1,057,297 Provision for credit losses, as reported $ 458,995 $ 635,013 $ 1,692,015 $ 536,447 Corrections $ 4,701 1.0% 1.0% $ 5,777 0.9% 0.9% $ 17,643 1.0% 1.0% $ 17,643 3.3% 3.2% Provision for credit losses, as corrected $ 463,696 $ 640,790 $ 1,709,658 $ 554,090 Pre-tax income, as reported $ 299,610 $ 221,428 $ 847,309 $ 277,773 Corrections $ (5,948) (2.0%) (2.0%) $ (7,250) (3.3%) (3.4%) $ (19,467) (2.3%) (2.4%) $ (19,467) (7.0%) (7.5%) Pre-tax income, as corrected $ 293,662 $ 214,178 $ 827,842 $ 258,306 Net income, as reported $ 242,299 $ 143,427 $ 607,490 $ 199,388 Corrections (4,810) (2.0%) (2.0%) (4,696) (3.3%) (3.4%) (13,957) (2.3%) (2.4%) (13,974) (7.0%) (7.5%) Net income, as corrected $ 237,489 $ 138,731 $ 593,533 $ 185,414 Comprehensive income, as reported $ 255,099 $ 150,672 $ 606,712 $ 199,009 Corrections $ (4,810) (1.9%) (1.9%) $ (4,696) (3.1%) (3.2%) $ (13,957) (2.3%) (2.4%) $ (13,974) (7.0%) (7.6%) Comprehensive income, as corrected $ 250,289 $ 145,976 $ 592,755 $ 185,035 EPS (diluted), as reported $ 0.67 $ 0.40 $ 1.69 $ 0.55 Corrections $ (0.01) (1.5%) (1.5%) $ (0.01) (2.5%) (2.6%) $ (0.04) (2.4%) (2.4%) $ (0.04) (7.3%) (7.8%) EPS (diluted), as corrected $ 0.66 $ 0.39 $ 1.65 $ 0.51 2 We have included other periods that may not be presented in the future SEC filings, for example three months ended March 31, 2017, to show that the impact was immaterial to previously reported periods as well. 3 In addition, the Company reviewed the impact on income statement for the three months ended December 31, 2017 and noted that in “no” instance was the above threshold breached (after normalizing the pre-tax and net income for significant items that occurred in Q4’17 – See 8K dated 01/31/2018) and therefore this change did not have any quantitatively material impact on the income statement. 4 The Company has intentionally included the same impact for three months ended and corresponding six or nine months ended periods, since the assessment was done at each quarter end and this analysis represents the highest possible impact for each quarter end period. 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12 months 12 months 12 months ended % of % of ended % of % of ended % of % of 12/31/2017 reported corrected 12/31/2016 reported corrected 12/31/2015 reported corrected Interest on finance receivables and loans, as reported $ 4,755,678 $ 5,026,790 $ 5,031,829 Corrections $ (2,094) (0.0%) (0.0%) $ (2,268) (0.0%) (0.0%) $ (1,957) (0.0%) (0.0%) Interest on finance receivables and loans, as corrected $ 4,753,584 $ 5,024,522 $ 5,029,872 Net finance and other interest income, as reported $ 4,317,773 $ 4,726,653 $ 4,732,573 Corrections $ (2,094) (0.0%) (0.0%) $ (2,268) (0.0%) (0.0%) $ (1,957) (0.0%) (0.0%) Net finance and other interest income, as corrected $ 4,315,679 $ 4,724,385 $ 4,730,616 Provision for credit losses, as reported $ 2,254,361 $ 2,468,200 $ 2,785,871 Corrections $ 17,411 0.8% 0.8% $ 6,170 0.2% 0.2% $ 4,477 0.2% 0.2% Provision for credit losses, as corrected $ 2,271,772 $ 2,474,370 $ 2,790,348 Pre-tax income, as reported $ 823,514 $ 1,160,711 $ 1,289,612 Corrections $ (19,505) (2.4%) (2.4%) $ (8,438) (0.7%) (0.7%) $ (6,434) (0.5%) (0.5%) Pre-tax income, as corrected $ 804,009 $ 1,152,273 $ 1,283,178 Net income, as reported $ 1,187,606 $ 766,466 $ 824,040 Corrections (12,678) (1.1%) (1.1%) (5,572) (0.7%) (0.7%) (4,111) (0.5%) (0.5%) Net income, as corrected $ 1,174,928 $ 760,894 $ 819,929 Comprehensive income, as reported $ 1,203,609 $ 792,600 $ 822,612 Corrections $ (12,678) (1.1%) (1.1%) $ (5,572) (0.7%) (0.7%) $ (4,111) (0.5%) (0.5%) Comprehensive income, as corrected $ 1,190,931 $ 787,028 $ 818,501 EPS (diluted), as reported $ 3.30 $ 2.13 $ 2.31 Corrections $ (0.04) (1.2%) (1.2%) $ (0.020) (0.9%) (0.9%) $ (0.01) (0.4%) (0.4%) EPS (diluted), as corrected $ 3.26 $ 2.11 $ 2.30 Balance Sheet (Iron Curtain Method) As of % of % of As of % of % of As of % of % of 06/30/2018 reported corrected 03/31/2018 reported corrected 12/31/2017 reported corrected Finance receivables held for investment, as reported $ 24,096,770 $ 22,587,358 $ 22,427,769 Corrections (14,487) (0.1%) (0.1%) (15,201) (0.1%) (0.1%) (17,411) (0.1%) (0.1%) Finance receivables held for investment, as corrected $ 24,082,283 $ 22,572,157 $ 22,410,358 Accrued interest receivable, as reported $ 286,164 $ 269,258 $ 326,640 Corrections (1,461) (0.5%) (0.5%) (1,247) (0.5%) (0.5%) (2,094) (0.6%) (0.6%) Accrued interest receivable, as corrected $ 284,703 $ 268,011 $ 324,546 Total assets, as reported $ 41,173,136 $ 40,045,188 $ 39,422,304 Corrections (15,947) (0.0%) (0.0%) (16,448) (0.0%) (0.0%) (19,505) (0.0%) (0.0%) Total assets, as corrected $ 41,157,189 $ 40,028,740 $ 39,402,799 Total equity, as reported $ 7,045,734 $ 6,726,015 $ 6,480,501 Corrections (12,296) (0.2%) (0.2%) (13,302) (0.2%) (0.2%) (12,678) (0.2%) (0.2%) Total equity, as corrected $ 7,033,438 $ 6,712,713 $ 6,467,823 Page 5 of 9 Privileged and Confidential

As of % of % of As of % of % of As of % of % of As of % of % of 09/30/2017 reported corrected 06/30/2017 reported corrected 03/31/2017 reported corrected 12/31/2016 reported corrected Finance receivables held for investment, as reported $ 22,667,203 $ 23,634,914 $ 23,444,625 $ 23,481,001 Corrections (17,643) (0.1%) (0.1%) (16,074) (0.1%) (0.1%) (5,777) (0.0%) (0.0%) (6,170) (0.0%) (0.0%) Finance receivables held for investment, as corrected $ 22,649,560 $ 23,618,840 $ 23,438,848 $ 23,474,831 Accrued interest receivable, as reported $ 330,554 $ 330,710 $ 306,742 $ 373,274 Corrections (1,824) (0.6%) (0.6%) (2,068) (0.6%) (0.6%) (1,473) (0.5%) (0.5%) (2,268) (0.6%) (0.6%) Accrued interest receivable, as corrected $ 328,730 $ 328,642 $ 305,269 $ 371,006 Total assets, as reported $ 38,765,557 $ 39,507,482 $ 39,061,940 $ 38,539,104 Corrections (19,467) (0.1%) (0.1%) (18,142) (0.0%) (0.0%) (7,250) (0.0%) (0.0%) (8,438) (0.0%) (0.0%) Total assets, as corrected $ 38,746,090 $ 39,489,340 $ 39,054,690 $ 38,530,666 Total equity, as reported $ 5,885,234 $ 5,678,733 $ 5,418,998 $ 5,238,619 Corrections (13,957) (0.2%) (0.2%) (11,793) (0.2%) (0.2%) (4,696) (0.1%) (0.1%) (5,572) (0.1%) (0.1%) Total equity, as corrected $ 5,871,277 $ 5,666,940 $ 5,414,302 $ 5,233,047 Management also considered the potential total impact of adjusting these items in the current year as an out-of-period adjustment on the projected financial statements for the three and six months ended June 30, 2018, as follows (dollars in thousands, except per share): Impact on income statement, as if these adjustments were recorded in three months and six months ended June 30, 2018 Six Months Ended Three Months Ended Cumulative Catch-up June 30, 2018 June 30, 2018 Interest on finance receivables and loans, as reported $ 2,270,673 $ 1,156,536 Interest on finance receivables and loans, with correction 2,269,212 1,155,075 Variance ($) $ 1,461 $ 1,461 Variance (% of corrected) 0.1% 0.1% Variance (% of reported) 0.1% 0.1% Net finance and other interest income, as reported $ 2,094,480 $ 1,068,639 Net finance and other interest income, with correction 2,093,019 1,067,178 Variance ($) $ 1,461 $ 1,461 Variance (% of corrected) 0.1% 0.1% Variance (% of reported) 0.1% 0.1% Provision, as reported $ 811,570 $ 352,575 Provision, with correction 826,057 367,062 Variance ($) $ (14,487) $ (14,487) Variance (% of corrected) -1.8% -3.9% Variance (% of reported) -1.8% -4.1% Pre-tax income, as reported $ 748,255 $ 448,645 Pre-tax income, with correction $ 732,308 $ 432,698 Variance ($) $ 15,947 $ 15,947 Variance (% of corrected) 2.2% 3.7% Variance (% of reported) 2.1% 3.6% Net income, as reported $ 576,940 $ 334,641 Net income, with correction 564,644 322,746 Variance ($) $ 12,296 $ 11,895 Variance (% of corrected) 2.2% 3.7% Variance (% of reported) 2.1% 3.6% EPS, as reported $ 1.59 $ 0.92 EPS, with correction 1.56 0.89 Variance ($) $ 0.03 $ 0.03 Variance (% of corrected) 1.9% 3.2% Variance (% of reported) 1.9% 3.1% Page 6 of 9 Privileged and Confidential

Other Disclosures: Management noted that this change would have impacted certain footnote disclosures, as follows: As of % of % of As of % of % of As of % of % of 06/30/2018 reported corrected 03/31/2018 reported corrected 12/31/2017 reported corrected TDR impairment*, as reported $ 1,496,580 $ 1,595,465 $ 1,731,320 Corrections - 0.0% 0.0% - 0.0% 0.0% - 0.0% 0.0% TDR impairment*, as corrected $ 1,496,580 $ 1,595,465 $ 1,731,320 Non-TDR allowance*, as reported $ 1,641,214 $ 1,586,557 $ 1,529,815 Corrections 10,500 0.6% 0.6% 10,500 0.7% 0.7% 10,500 0.7% 0.7% Non-TDR allowance*, as corrected $ 1,651,714 $ 1,597,057 $ 1,540,315 Recorded investment in TDRs, net of impairment*, as reported $ 4,435,629 $ 4,382,717 $ 4,530,112 Corrections (3,983) (0.1%) (0.1%) (4,026) (0.1%) (0.1%) (6,085) (0.1%) (0.1%) Recorded investment in TDRs, net of impairment*, as corrected $ 4,431,646 $ 4,378,691 $ 4,524,027 Allowance*, as reported $ 3,137,794 $ 3,182,022 $ 3,261,135 Corrections 10,500 0.3% 0.3% 10,500 0.3% 0.3% 10,500 0.3% 0.3% Allowance*, as corrected $ 3,148,294 $ 3,192,522 $ 3,271,635 Retail installment contracts acquired individually, as reported $ 24,039,237 $ 22,526,948 $ 22,362,509 Corrections (14,487) (0.1%) (0.1%) (15,201) (0.1%) (0.1%) (17,411) (0.1%) (0.1%) Retail installment contracts acquired individually, as corrected $ 24,024,750 $ 22,511,747 $ 22,345,098 * On retail installment contracts acquired individually As of % of % of As of % of % of As of % of % of As of % of % of 09/30/2017 reported corrected 06/30/2017 reported corrected 03/31/2017 reported corrected 12/31/2016 reported corrected TDR impairment*, as reported $ 1,782,114 $ 1,686,159 $ 1,604,489 $ 1,611,295 Corrections - 0.0% 0.0% - 0.0% 0.0% - 0.0% 0.0% - 0.0% 0.0% TDR impairment*, as corrected $ 1,782,114 $ 1,686,159 $ 1,604,489 $ 1,611,295 Non-TDR allowance*, as reported $ 1,589,151 $ 1,760,809 $ 1,836,730 $ 1,799,760 Corrections 10,500 0.7% 0.7% 10,500 0.6% 0.6% - 0.0% 0.0% - 0.0% 0.0% Non-TDR allowance*, as corrected $ 1,599,651 $ 1,771,309 $ 1,836,730 $ 1,799,760 Recorded investment in TDRs, net of impairment*, as reported $ 4,548,217 $ 4,225,079 $ 4,180,543 $ 4,026,497 Corrections (5,501) (0.1%) (0.1%) (4,452) (0.1%) (0.1%) (3,964) (0.1%) (0.1%) (4,870) (0.1%) (0.1%) Recorded investment in TDRs, net of impairment*, as corrected $ 4,542,716 $ 4,220,627 $ 4,176,579 $ 4,021,627 Allowance*, as reported $ 3,371,265 $ 3,446,968 $ 3,441,219 $ 3,411,055 Corrections 10,500 0.3% 0.3% 10,500 0.3% 0.3% - 0.0% 0.0% - 0.0% 0.0% Allowance*, as corrected $ 3,381,765 $ 3,457,468 $ 3,441,219 $ 3,411,055 Retail installment contracts acquired individually, as reported $ 22,599,161 $ 23,410,227 $ 23,200,111 $ 23,219,724 Corrections (17,643) (0.1%) (0.1%) (16,074) (0.1%) (0.1%) (5,777) (0.0%) (0.0%) (6,170) (0.0%) (0.0%) Retail installment contracts acquired individually, as corrected $ 22,581,518 $ 23,394,153 $ 23,194,334 $ 23,213,554 * On retail installment contracts acquired individually Management noted the impact of this change on other footnotes (as shown above) was not material, i.e., did not breach the 10% threshold individually or in aggregate for any of the disclosures, nor were any trends materially affected • Impact on previous reported SUM and OOP5: The Management also analyzed the impact of this change on current and previously reported SUM and OOP reports, since this item could potentially be included in the SUM and or OOP reports now. Management noted that, even after including this item in the SUM and OOP reports for the various periods listed above, the total percentage of total pretax and after-tax adjustments to pretax income was less than the established thresholds. Qualitative Considerations Per SEC Staff Accounting Bulletin (SAB) No. 99, Materiality (now codified in ASC 250, Accounting Changes and Error Corrections), an error is considered material if it would impact the decisions of users of the financial statements. Magnitude by itself, without regard to the nature of the item and the circumstances in which the judgment has to be made, generally will 5 SUM - Summary of uncorrected misstatement and OOP – Out of period adjustments Page 7 of 9 Privileged and Confidential

not be a sufficient basis for a materiality judgment. Therefore, management considered the following qualitative factors as well: 1. Nature of and reason for differences: The potential errors were not fraudulent or intentional misstatements. The Company has historically reported delinquencies based on a 50% required minimum payment rule for the Core portfolio and a 90% required minimum payment rule for the Chrysler loans. We continue to believe that the 50% threshold was appropriate for core loans (originated pre 1/1/17), which were grandfathered when we changed the rule to 90% for all new originations post 1/1/17, based on our historical and current servicing practices. 2. Whether the misstatement arises from an item capable of precise measurement or whether it arises from an estimate and, if so, the degree of imprecision inherent in the estimate: This potential error is capable of precise measurement for past due disclosure purposes when the disclosure is based on the 90% threshold as compared to the manner by which we are servicing the customer. However, although not contemplated herein, there will be an element of imprecision when evaluating the reasonableness of the revenue in total if the change is made. 3. Whether the misstatement masks a change in earnings or other trends: The Company produced significant, positive, earnings for each period and the changes would have not have masked a change in those earnings or trends. We understand that the primary focus of SC’s investors on our reported results (other than past due disclosures) has been on earnings, provision for credit losses, total available liquidity, allowance ratio and return on assets/equity ratios. The Company concluded that the impact of this change was insignificant (if any) on the any of these metrics. 4. Whether the misstatement changes a loss into income or vice versa: The Company produced significant positive earnings on both an as- reported and as-corrected basis. 5. Whether the misstatement concerns a segment or other portion of the registrant's business that has been identified as playing a significant role in the registrant's operations or profitability: SC has only one segment, Consumer Finance. 6. Whether the misstatement affects the registrant’s compliance with regulatory requirements: SC does not have stand-alone regulatory requirements, such as capital ratios. 7. Whether the misstatement affects the registrant’s compliance with loan covenants or other contractual requirements: SC’s only financial statement-related loan covenants are minimum tangible net worth requirements, on certain financing facilities. The amounts of the errors described in this memo would not impact equity enough to impact compliance. 8. Whether the misstatement has the effect of increasing management’s compensation – for example, by satisfying requirements for the award of bonuses or other forms of incentive compensation: This change would not have impacted management compensation. 9. Whether the misstatement involves concealment of an unlawful transaction. The errors were unintentional and do not involve concealment of an unlawful transaction. Market Reaction We understand that the primary focus of SC’s investors on our reported results during these periods has been on earnings, provision for credit losses, total available liquidity, allowance ratio and return on assets/equity ratios. Provision for credit losses: As discussed above, the allowance for loan losses, which drives provision expense, is seen as a metric indicative of credit quality and is a key focus of SC’s investors; accordingly, a large quantitative error in this metric could be material to an investor but only when the overall level (on balance sheet) changes materially. Given the sizable allowance for credit losses relative to the overall balance sheet, investors expect volatility in the income statement and revert to evaluating overall level of reserves as well as applicable balance sheet ratios such as allowance coverage ratio. We note that provision expense was not impacted by more than 5% (individually or in aggregate) for all the periods presented. Liquidity: The amounts of the errors described in this memo would not impact equity significantly enough to impact compliance with loan covenants. Further, the errors are non-cash in nature and do not impact operations or liquidity. Allowance ratio: These errors would not have materially altered our overall allowance coverage ratio. Page 8 of 9 Privileged and Confidential

Other trends: We believe that these errors would not have materially altered our various trends on yield, net interest margin, and return on assets / equity. Balance sheet: The change in assets and liabilities is less than 5% of individual items. Earnings: Because the net error remaining to be corrected have less than a 5% impact on pre-tax income, net income and EPS, we believe that there would not be a significant market reaction to the errors. Internal Controls Considerations Management’s accounting conclusions for this change were well supported by internal documentation and governance, including comprehensive memo documentation, committee presentation materials, reviews by the SC Disclosure Committee and approval by the Audit Committee as a part of the 10-Q disclosures included in all filings from Q1 2017 forward. Accordingly, we do not consider this issue a control deficiency. Conclusion Based on the above quantitative and qualitative considerations, this analysis demonstrates that the incremental impact to the past due and other delinquency statistics, financial position and results of operations is immaterial to all historical periods of presentation as well as to the June 30, 2018 financial statements. Page 9 of 9 Privileged and Confidential

Exhibit B Additional Data points for SC analysis SC’s judgement regarding its change in estimate was informed by the following data. SC evaluated negative trends, coupled with a forecast of overall TDR portfolio composition which indicated significant growth in the percentage of lower credit quality TDR loans through 2017 (driven primarily by the seasoning of the 2015 origination vintage). The conclusion to change accrual status and record cash received on a cost recovery basis was necessary since these new TDR vintage pools were not expected to perform as well as earlier dated pools. Given the timing of SC’s decision (Q1 2017) and relative to the most recent data available at that time (trends emerging in middle to late 2016), to operationalize this change in estimate SC determined that loans designated as TDRs post January 1, 2017 that are 60 days delinquent at the time of the TDR or are modified a third time, will no longer meet the reasonable collectability expectations and should be placed on non-accrual and cost recovery status for reporting purposes. The date of January 1 was coincidental to the timing of the analysis and related data. Table 1: Data represents the Dec 2014, Dec 2015, Dec 2016 TDR vintages observed six months after the TDR event. We used this data to initially inform us as to the types of modifications that create the TDR, and the basis of accrual for the upcoming TDR Vintage. Note the performance rate above 80% for each static pool. Analysis – Interest is Dec 2014 TDR vintage Dec 2015 TDR vintage Dec 2016 TDR vintage Reasonably Assured (performance observed in 2015) (performance observed in 2016) (performance observed in 2017) 6-Month 6-Month 6-Month % of TDR in this Performance % of TDR in this Performance % of TDR in this Performance TDR driver category Rate category Rate category Rate Extensions 63% 84% 62% 85% 60% 85% TRIPP modification 34% 97% 36% 96% 38% 95% Others 3% 86% 2% 87% 1% 88% Total 100% 88% 100% 89% 100% 89% Table 2: Data represents the Dec 2014, Dec 2015, Dec 2016 TDR vintages observed six months after the TDR event, with rows for delinquency status at TDR (exact same population as Table 1.) Our assessment further disaggregates the TDR Vintage performance data by past due status, which informs us further as to what types of criteria have higher risk of performance. Note collectability thresholds met across all categories, but 61+ performance rates (inclusive of the 90+, which are not material) have been right at the threshold of ~75%. Page 1 of 4 Privileged and Confidential

Exhibit B Additional Data points for SC analysis Analysis – Interest is Dec 2014 TDR vintage Dec 2015 TDR vintage Dec 2016 TDR vintage Reasonably Assured (performance observed in 2015) (performance observed in 2016) (performance observed in 2017) Delinquency Status of the loans 6-Month 6-Month 6-Month the day before the loans became % of TDR in Performance % of TDR in this Performance % of TDR in this Performance a TDR this category Rate category Rate category Rate Current 11% 98% 10% 97% 10% 97% 1-30 35% 96% 41% 95% 39% 94% 31-60 32% 87% 32% 87% 34% 88% 61-90 16% 73% 13% 75% 14% 75% >90 5% 65% 4% 70% 3% 68% Total 100% 88% 100% 89% 100% 89% In a separate analysis, we further disaggregated the TDR loans in the December 2016 TDR vintage1 to evaluate whether the performance of older origination vintages is masking the performance of the 2015 origination vintage and noted that the performance rate for the 2015 origination vintage was not materially different as a stand-alone factor. Table 3: Monthly 2014 - 2016 TDR vintage showing average original FICO and original LFS score. Note the significant dip in average FICO score and LFS2 in monthly TDR vintages starting mid-20163. This indicated that the new TDRs were a higher credit risk on average. We used this data to inform us as to the underlying credit risks inherent in each TDR Vintage. These risks inform our view of qualitative factors in consideration of our accrual determinations for the TDR vintage. The highlighted points, which is the conclusion of the solid lines, reflects the data we had available when we formed our estimate specific to the 2017 TDR Vintage. The future periods reflect actual performance subsequent to when we changed our estimate for the 2017 TDR Vintage. 1 December 2015 TDR vintage included an immaterial amount of loans that were originated in 2015 and therefore we performed this analysis only for December 2016 TDR vintage 2 LFS is an SC proprietary calculation utilized by Company to assess the credit quality of a particular loan. It is driven by relevant credit metrics (i.e. FICO, LTV, etc.). Lower LFS scores generally represent lower credit quality loans. 3 March 2016 information was the most recent information available at the time the decision to make the change was made, since we analyzed performance 6 months and/or 12 months after the event. Page 2 of 4 Privileged and Confidential

Exhibit B Additional Data points for SC analysis Table 4: Data represents third deferrals, by monthly TDR vintage and showing performance 6 and 12 months later. Our assessment further disaggregates the TDR performance, irrespective of TDR Vintage, to assess instances of a third deferral. This informs us further as to whether existing TDRs are paying even if they receive another modification as a TDR (i.e. are losses being delayed or are borrowers honoring their terms.) While the collectability is above 75% for all vintages, note the significant dip in performance rates early in 2016 as compared to prior periods; the company had this data at the time of the 2017 change in estimate. The dotted lines reflect data now available based on actual performance; this data was obtained subsequent to the change in estimate. Analysis of TDRs that received third instance of deferral 84% 92% 82% 90% 80% 88% 78% 86% 76% 84% Performance rate Performance 74% 82% 12 months 6 months Month of TDR's Third Deferral, Performance observed 6 and 12 months later Represents the month in which the TDR loans received a third instance of deferral and its performance rate six and 12 months after the third instance of deferral. Page 3 of 4 Privileged and Confidential

Exhibit B Additional Data points for SC analysis In a separate analysis, we further disaggregated the TDR loans that received a third instance of extension, starting January 20164, to evaluate whether the performance of older origination vintages is masking the performance of the 2015 origination vintage and noted that the performance rate for the 2015 origination vintage was not materially different as a stand-alone factor. In summary, while the quantitative data was not indicative of an absolute breach in SC’s established thresholds, qualitatively the deteriorating credit quality indicators of FICO and LFS scores, coupled with the downturn in third deferrals, required SC to take action. To operationalize the emergence of this increased risk, management concluded that the loans already 60 days past due at time of TDR could breach the 75% probability threshold, and that loans receiving a third deferral could continue to deteriorate, hence a nonaccrual and cost recovery determination for these loans was a reasonable proxy to address the increased risk. 4 Prior to January 2016, total TDR portfolio included an immaterial amount of loans that were originated in 2015 and therefore we performed this analysis for the months starting January 2016. Page 4 of 4 Privileged and Confidential


1.	Required minimum payments: For Core (i.e. subprime auto) loans originated after January 1, 2017, SC determines past due status using a 90% required minimum payment threshold, while continuing to use a 50% minimum payment threshold to report past due status on Core loans originated prior to 1/1/2017.